EVENT DESCRIPTION
The three-year statute of limitations on IRS assessment is one of the most useful tools available to a taxpayer's representative — but only when it has actually run. The Internal Revenue Code carves out more than a dozen exceptions that extend this period, and several of them eliminate the limitations period entirely, sometimes without either the taxpayer or the practitioner realizing it.
This program provides a practitioner-focused survey of IRC §6501 and the circumstances under which the ordinary three-year assessment period is extended, suspended, or never starts running at all. Topics include fraud and unfiled returns, agreed extensions under Form 872, the six-year rule for substantial omissions of income (including the unresolved treatment of overstated basis), unreported foreign assets and gifts, undisclosed listed transactions, and the reporting failures that can leave an entire tax year open to assessment. The program will also address common practitioner traps — including the frequent confusion between FBAR reporting failures and the Internal Revenue Code's own foreign-asset disclosure rules.
Attendees will leave with a practical framework for evaluating whether a client's assessment period has actually closed, and with a working knowledge of the disclosure standards that determine whether several of the most significant exceptions apply.
EVENT OBJECTIVE
By the end of this program, participants will be able to:
1. Identify the general three-year assessment period under §6501(a) and the filing-date mechanics that start it running.
2. Recognize which §6501(c) and (e) exceptions extend the assessment period — or eliminate it entirely — including fraud, unfiled returns, agreed extensions, substantial omissions, and unreported foreign assets, gifts, and listed transactions.
3. Apply the “adequate disclosure” standard that closes off several of these exceptions, and identify when it has not been met.
4. Spot the practitioner traps most likely to leave a client's assessment period open longer than expected.
